Important Tax Dates for the 2020 Calendar Year

Every year, the IRS announces the opening date for when it will begin to accept tax returns from the previous tax year. This year, the IRS will begin processing 2019 returns on January 27, 2020. Taxpayers who file their 2019 returns electronically before the January 27 date will not receive any preference over filers who…

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Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary Disclosure Program

Now, More than Ever, Taxpayers with Lingering Offshore TaxNon-Compliance Must Seek Professional Assistance On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important updates regarding its Voluntary Disclosure Practice (“the Memo”).  Although the Memo provides significant guidance as a result of the closing of the Offshore Voluntary Disclosure Program (“OVDP”), which ended…

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Collection: Expatriation with No Tax, Interest or Penalties: New Relief Procedures for Certain Former Citizens

This article was originally published in the Journal of Tax Practice and Procedure, August – September 2019 edition. Introduction On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010.1 Under the new IRS Relief Procedures,…

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Collection: Disputing a Notice of Federal Tax Lien Before It Is Filed

I. Introduction Internal Revenue Service (“IRS”) bank account levies and wage garnishments count among the scariest tax collection weapons in the U.S. Treasury arsenal. However, the Notice of Federal Tax Lien (“NFTL”) can, in many cases, pose a more immediate and substantial threat to individuals and businesses with outstanding tax liabilities. In January 2018, the…

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Collection: When Uncle Sam Crosses the Border: What is in the IRS International Collection Toolbox?

This article was originally published in the Journal of Tax Practice and Procedure, April – May 2019 edition. The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include locating and contacting the taxpayer, the increasing complexity of international…

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Colliot and Its Effect on Penalties for Potential FBAR Violations: Ruling Provides for Significant Limitation on Amount of Penalties

On May 15, 2018, the United States District Court for the Western District of Texas issued an important ruling concerning the application of willful FBAR penalties under 31 U.S.C. § 5321.  In United States v. Colliot, Case No. AU-16-CA-01281-SS (W.D. Tex. 2018), the court held that the Internal Revenue Service (“the Service”) could not assess…

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Responding to an IRS Letter 5935 and IRS Form 15023: What to Do (and Not Do) to Resolve Your Offshore Tax Issues

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”) or who submitted a voluntary disclosure letter within the OVDP.  For those that receive these letters – IRS Letter 5935 and IRS Form 15023…

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Planning to Travel Abroad? Don’t Let the IRS Stop You at the Border. Understanding Recent Guidance Regarding Passport Revocation Rules Under I.R.C. § 7345

As part of the Fixing America’s Surface Transportation Act (“FAST Act”) of 2015, Congress mandated that the State Department deny any passport application for an individual, or revoke any previously issued passport for an individual, if the Internal Revenue Service (“the Service”) certifies that the individual has a “seriously delinquent tax debt.”  In early 2018,…

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2017 Tax Act: Pass-Through Tax Cut Raises Questions

Since Congress passed the Tax Cuts and Jobs Act (the “Act”) on December 20, 2017,  tax professionals and the general public alike have been grappling to understand the Act’s full implications. One noteworthy change brought about by the Act is a new 20 percent deduction of certain business income for qualifying pass-through entities. The pass-through…

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Continuing an Annual Trend, Comptroller Opens Tax Season by Suspending Tax Preparers

On February 2, 2018, the Comptroller issued a press release announcing that he has suspended the processing of electronic tax returns for nine additional tax preparers.  A copy of the press release can be found here.)  The Comptroller acknowledged that these preparers were suspended based upon technology designed to spot instances of fraud used by…

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